Russia-related General License 74 - Authorizing the Wind Down and Rejection of Transactions Involving East-West United Bank (November 2, 2023)

Date issued: Nov. 02 2023

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TURBOFAC Commentary (196 words)

Notes:

1) Compare Russia-related General License 60. This GL is typical of the now-standard GLs for the wind down/rejection of transactions with blocked Russian financial institutions.

2) See related debt/equity divestment GL at Russia-related GL 75.

3) Refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, for comments on the scope of the typical wind down GL containing language similar to Russia-related GL 60 and Russia-related GL 61.

4) The substantive portion of paragraph (b) is identical to that of Russia-related General License 60, except with the addition of "and return to the originator or originating financial institution or their successor-in-interest..." Query: when a USP financial institution is...